Update as of December 31, 2025: We have now received two (2) confirmed W2 approvals again this December. If you would like to assess whether this pathway may work for your specific case, feel free to reach out for a consultation.
Over the past few weeks in November, we have been speaking constantly with fellow Spanish immigration consultants and lawyers. A clear pattern is emerging that affects anyone who plans to apply for Spain’s Digital Nomad Visa (or International Teleworker Residence Authorization) as an employee using a Certificate of Coverage from their home country.
Right now, my recommendation for most employee applicants is simple: do not submit your application just yet. Here is why.
What Is Happening With Certificates Of Coverage
Until very recently, many successful Digital Nomad Visa applications who applied as employees relied on a Certificate of Coverage from the applicant’s home country Social Security system. We talked about this in our most recent 2025 DNV webinar. This was commonly used for:
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U.S. W2 employees
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Canadian employees
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UK employees with A1 certificates
These certificates used to be accepted as proof that the worker was already covered in their home country and did not need to pay into Spanish Social Security.
In the last two (2) weeks, however, UGE (the Spanish unit that decides these applications) has started systematically rejecting Certificates of Coverage for international teleworkers.
Colleagues have already received denials for W2 cases that would almost certainly have been approved a short time ago. We and other lawyers are reporting the same in professional groups and forums, and the recent immigration congress discussion strongly points in the same direction.
From the language in the decisions, additional document requests, and now the congress commentary, UGE appears to treat Certificates of Coverage as applying only to traditional intra-company assignments, not to fully remote workers who move to Spain and work from there.
To add to this, the former head of UGE, who held the position until November 2024, appears to have returned. The timing of this shift strongly suggests that the stricter treatment of CoCs is linked to this change in leadership, so for now we are working on the basis that CoCs are effectively off the table for most remote workers unless a very narrow exception is later clarified in writing.
Why This Matters If You Are A W2 Employee
If your Digital Nomad Visa strategy is “I stay on payroll as a W2 employee and we present a Certificate of Coverage,” you are very likely falling into the group that is now being questioned.
Sending in an application under a criterion that UGE is actively rejecting can mean:
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Wasting your government fees
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Losing months of time
This is exactly what I want to help you avoid.
Update After The Late-November Conference
At the immigration conference on 27 and 28 November, UGE representatives did not reopen the door to using Certificates of Coverage for US W2 remote workers. If anything, the feedback shared there confirmed what we were already seeing in practice: that CoCs are not being accepted as a valid basis for Digital Nomad Visa employee cases.
What we are watching for now is not whether CoCs will be broadly accepted again, but whether UGE will publish any very narrow exception or specific wording that might apply in limited scenarios. Until we see clear written criteria or a consistent pattern of approvals to the contrary, we are treating CoC-based W2 applications as high-risk.
Because of that, I am telling new and prospective clients:
If you are a W2 employee, it is safer to wait before filing your Digital Nomad Visa application.
Alternatives We Are Exploring For Our Clients
If you do not want to wait or if you already suspect that the Certificate of Coverage route will be problematic for you, there are other paths that UGE has been accepting until now. These include:
1. Switching To Self-Employed Status
Restructuring so that the main applicant works as a contractor or freelancer and can register under RETA, the Spanish self-employed Social Security regime, once the visa is approved.
This route usually involves:
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A freelance or contractor agreement instead of an employment contract (which must be in place at least 3 months before the application)
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Invoices instead of payslips
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A clear description of remote, independent professional services
2. Employer Registration With Spanish Social Security
Another option is asking the foreign employer to register with Spanish Social Security so that they can enroll the worker after the visa is granted.
This is technically possible, but it is long and bureaucratic. Many employers are reluctant to do it unless they have a strong business reason to have staff in Spain.
3. For U.S. Applicants: 1099 Contractor Status
For U.S. employees, similar to Option 1 above, a practical compromise can be to switch from W2 to 1099 contractor status for at least three (3) months and base the application on contractor income instead of employment income.
This option usually works best when:
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The employer is open to a temporary change in status
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The worker can manage the tax and accounting implications
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There is enough time to build a clear track record as a contractor before filing
What You Can Do Now
If you are a potential applicant who has not filed yet and you are currently on W2 or similar employee payroll, you can already start preparing:
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Talk to your employer. Ask whether they would ever consider:
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Supporting a switch to contractor status, or
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Registering with Spanish Social Security.
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Organise your documents. Even if we decide to wait on filing, you can already gather contracts, invoices, and bank statements so that we can move quickly once we have clarity.
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Stay informed. The rules for this visa are always evolving quickly. Working with a team that is in contact with other practitioners and attending these conferences in real time is crucial.
My Recommendation For Now
Until we have official clarification from the late November conference or further issuances from the UGE, I do not recommend rushing a W2-based Digital Nomad Visa application that relies on a Certificate of Coverage.
Waiting a short time now can save you from a refusal that needs to be fixed later. In the meantime, we can prepare your file and explore alternative structures so that you are ready to move as soon as the dust settles.
If you are unsure how this new pattern might affect your specific situation, or if you want to explore self-employed or contractor options, feel free to reach out for a consultation. This is a fast moving area, and it helps to have someone watching the changes for you full time.
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